Very Important / Notice: Lawyers across the country, Notaries and Notary Assistants across the country

My previous note regarding warnings about cases in which Iranian nationals residing abroad grant powers of attorney using domestic SIM cards and the Sana system — is this the one you meant?

I am now reiterating: Lawyers across the country are among the persons covered under Article 6 of the Anti-Money Laundering Law of 2007 (with subsequent amendments), who, according to Clause (a) of Article 7 of this law, are obliged to:

"Verify the identity of clients and beneficial owners, and, in cases where actions are taken by a representative or attorney, verify the position and identity of the representative, attorney, and principal."

Additionally, notaries, their assistants, and lawyers are classified as non-financial professions under Clause 7 of Article 1 of the Executive Regulations for Combating and Preventing Money Laundering and Financing of Terrorism, amended on October 19, 2025, by the Cabinet.

According to received reports, the Financial Intelligence Unit and the Secretariat of the High Council for Combating Money Laundering and Terrorist Financing have officially notified the Center for Lawyers, Family Law Experts and Consultants of the Judiciary, the Bar Association, and the Organization for Registration of Deeds and Properties that, pursuant to Article 149 and Clause 3 of the aforementioned Executive Regulations, notaries, notary assistants, lawyers, legal specialists, or employees of legal institutions are subject to anti-money laundering regulations. This includes preventive measures such as verifying clients’ identities, reporting suspicious transactions and operations, and maintaining records.

They are also strongly advised to refrain from granting power of attorney in the common manner currently practiced. Powers of attorney from Iranian nationals residing abroad must be obtained through the Mikhak system or Adl Iran International, with real identity verification. Granting power of attorney via SMS verification to a mobile phone of these individuals that is held by relatives inside the country is illegal, constitutes a form of money laundering, and is subject to criminal penalties.

Take the warnings of the Financial Intelligence Unit in this regard seriously.